Epstein Secrets

any evidence to prove Epstein's lack of remorse for this abuse, a showing critical for securing substantial punitive damages. In the fall of 2009, Michael Fisten, an investigator working for Edwards, heard from an author that Daily News reporter George Rush had made a recording of Epstein discussing the sexu

ard from an author that Daily News reporter George Rush had made a recording of Epstein discussing the sexual abuse of minor girls. The author told Fisten that Rush had played the recording for her and two other persons. The author concluded: "You've got to get that tape." Fisten then called Rush. Rus

pe was not protected by the journalist's privilege. (Judge McKenna's Opinion is attached as Ex. 5 to Lewis Aft). Applying Gonzales v. Nat 'I Broad. Co., Inc., 194 F.3d 29 (2d Cir. 1999) (Gonzales ///), the district court explained that a reporter's privilege extended even to non-confidential sources. The

unsel responded that they would do so only if movants would stipulate to the accuracy of all facts alleged in the subpoenas of Brad- ley Edwards and Michael Fisten submitted in support of Doe's opposition to movants' motion to quash or for a protective order. I declined. 1 declare under penalty of perjury that

interview with Jeffrey Epstein but whom I did not identify in my prior affidavit. Hearing that refreshed my memory that in fact I did speak to Mr. Fisten about the interview. The attorney's representation that the interview with Mr. Epstein must have occurred prior to October 22, 2009, because my conv

hly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 1996). Gall

unsel responded that they would do so only if movants would stipulate to the accuracy of all facts alleged in the subpoenas of Brad- ley Edwards and Michael Fisten submitted in support of Doe's opposition to movants' motion to quash or for a protective order. I declined. I declare under penalty of perjury that

interview with Jeffrey Epstein but whom I did not identify in my prior affidavit. Hearing that refreshed my memory that in fact I did speak to Mr. Fisten about the interview. The attorney's representation that the interview with Mr. Epstein must have occurred prior to October 22, 2009, because my conv

hly material and relevant, (2) necessary or critical to its claims, and (3) not obtainable from other available sources. Gonzales v. National Broad. Co., Inc., 194 F.3d 29 [27 Med.L.Rptr. 2459] (2d Cir. 1999), Krase v. Graco Children's Products, Inc., 79 F.3d 346 [24 Med.L.Rptr. 1599] (2d Cir. 1996). Gall

from an author that Daily News reporter George Rush had made a tape recording of Epstein discussing the sexual abuse of minor girls. The author told Fisten that Rush had played the tape for her and two other persons. The author concluded: "You've got to get that tape." Fisten then called Rush. Rush des

3 privilege protecting journalists' confidential sources but also a privilege that extends to nonconfidential materials. Gonzales v. Nat'l Broad. Co., Inc., 194 F.3d 29, 33 (2d Cir. 1999) ("Gonzales III").2 In the present case, Mr. Rush's source -- Mr. Epstein -- is not confidential: Mr. Rush disclosed